Finding Text
Finding Number: 2024‐001
Repeat Finding: No
Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939
Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Procurement, Suspension, and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable state and local
laws and regulations, provided that the procurements conform to applicable federal statutes and the
procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are
prohibited from contracting with or making subawards under covered transactions to parties that are
suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity
at a lower tier, the non‐federal entity must verify that the entity, as defined in 2 CFR §180.995 and
agency adopting regulations, is not suspended or debarred or otherwise excluded from participating
in the transaction. This verification may be accomplished by checking the System of Award
Management (SAM) maintained by the General Services Administration (GSA), collecting a
certification from the entity, or adding a clause or condition to the covered transaction with that
entity (2 CFR §180.300).
Condition
Adequate internal controls over procurement procedures to ensure compliance with Uniform
Guidance regulations and guidelines were not in place. Verification of suspension and debarment was
not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at
least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the
requirement for performing a suspension or debarment verification check on vendors procured with
federal funds.
Cause
Emerge’s internal controls over procurement of goods and services were not adequate.
Effect
Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to
suspension and debarment. However, it was subsequently determined that the vendor utilized was
not suspended or debarred.
Context
During our review of procurement, we noted that Emerge does not have a policy or procedure in
place that requires a verification check of suspension and debarment for covered transactions. For
one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check.
Audit procedures determined the vendor was not suspended or debarred.
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
Management should develop and implement policies and procedures over procurement to ensure
compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326.
Views of Responsible Officials
See Corrective Action Plan.